Ingram Industries, Inc. & Subsidiaries - Page 28




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          $30,000, then a 1.6-percent maintenance cost would equal $480.              
          Relatively and comparably, the $100,000 and $480 appear, at least           
          in size, to represent an incidental as opposed to a major repair,           
          improvement, or procedure.8                                                 
               Petitioners also emphasize that the maintenance procedures             
          take from 10 to 12 days and that the procedures are performed               
          during off-peak season, whereas complete overhauls are performed            
          by third parties and the engine is removed from the towboat                 
          during a 3- to 5- month process.  Accordingly, there is a                   
          substantial time differential between petitioners’ procedures and           
          a complete overhaul.  By comparison, up to 5 months of towboat              
          revenue could be lost during an overhaul.                                   
               We think it is significant that petitioners perform the                
          procedures at a time when the engines are completely serviceable            
          and the purpose of performing the procedures is to keep the                 
          towboat engines in good operating condition.  This is in contrast           
          to the cases relied on by respondent where the property was not             
          serviceable and had to be replaced or completely rebuilt or                 
          overhauled.  For example, respondent relies on Ruane v.                     

               7(...continued)                                                        
          cost of removal, installation, and refitting a new or rebuilt               
          engine.                                                                     
               8 In that regard, towboats are operated about 8,000 hours              
          per year, whereas an automobile, for example, would generally be            
          operated for substantially fewer hours annually.  Accordingly,              
          the cost of normal maintenance for a towboat should be                      
          comparatively larger in a shorter period of time.                           





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